Parrish et al v. National Football League Players Incorporated

Filing 536

Letter Brief re Motion to Strike Testimony filed byBernard Paul Parrish, Walter Roberts, III, Herbert Anthony Adderley. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D)(Katz, Ronald) (Filed on 11/3/2008)

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Exhibit C to Plaintiffs' Letter Brief Striking Statements by Defendants' Witnesses Stephen Saxon, Esq. October 1, 2008 Page 1 1 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 2 SAN FRANCISCO DIVISION 3 4 BERNARD PAUL PARRISH, HERBERT ANTHONY ADDERLEY WALTER ROBERTS, III, 5 Vs. 6 Plaintiffs, CASE NO.. C 07 00943 NATIONAL FOOTBALL LEAGUE PLAYERS ASSOCIATION and 7 NATIONAL FOOTBALL LEAGUE PLAYERS INCORPORATED d/b/a 8 PLAYERS INC, Defendants. 9 10 11 ---- -- -------------------DEPOSITION OF STEPHEN SAXON, ESQ. 12 13 14 15 16 17 October 1, 2008 9:00 a.m. 700 12th Street, N.W. Washington, D.C. 18 19 Linda Ann Crockett, a Notary Public 20 21 22 23 24 25 Stephen Saxon, Esq. October 1, 2008 Page 16 1 BY MR. LeCLAIR: 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Q. If you look at the first page, Mr. Saxon, there's questioning here about the independent assessment of the $8 million reallocation that occurred in 2006. And we will talk about it in detail. I'm not meaning to go into it right now. I'm simply asking whether Mr. Berthelsen's testimony that you gave advice about that subject is correct? MR. FEHER: can answer. A. Q. What was your question? Was Mr. Berthelsen.correct that you Objection to form. You did provide legal advice about the $8 million reallocation that occurred in 2006? A. That's correct. 17 18 19 20 21 22 23 24 25 Q. If you look at Page 3 of Exhibit 3 to your deposition? A. Q. Exhibit 3. Page 3. There's a statement at the top that, quote, Steve Saxon, who I mentioned previously, appears at every player rep meeting, and I'm sure he would have talked about it, most certainly. Closed quote. Is it accurate that you appeared at every player Stephen Saxon, Esq. October 1, 2008 Page 17 1 2 3 4 rep meeting? A. I've been at every player rep meeting since about 1993 or so. Q. And is that Board of Player 5 6 7 8 9 10 11 Representatives? A. Q. A. Q. That's correct. That runs the NFLPA? That's correct. What is your role at such meetings? MR. FEHER: Objection. You can answer. 12 13 14 15 16 17 A. Q. I'm outside tax counsel. Are you responsible in any way for keeping minutes of such meetings? A. Q. A. No. Are minutes kept of such meetings? Yes. 18 19 Q. A. Who keeps them? Richard Berthelsen. 20 21 22 Q. Are agendas prepared for such meetings? A. My understanding is that, yes, there 23 24 25 are. Q. And are presentations made at such meetings? Stephen Saxon, Esq. October 1, 2008 Page 172 1 2 3 REPORTER'S CERTIFICATION STATE OF MARYLAND COUNTY OF BALTIMORE 4 5 6 I, Linda A. Crockett, a Notary Public of the State of Maryland, do hereby certify that the within named, STEPHEN SAXON, was 7 8 9 10 11 12 13 14 15 16 17 18 19 20 deposed at the time and place herein set out, and after having been duly sworn by me, was interrogated by counsel. I further certify that the examination was recorded stenographically by me, and this transcript is a true record of the proceedings. I further certify that the stipulations made herein were entered into by counsel in my presence. I further certify that Iam not of counsel to any of the parties, nor an employee of counsel, nor related to any of the parties, nor in any way interested in the outcome of this action. 21 22 23 As witness my hand and notarial seal this 3rd day of October, 2008. My commission expires: December 1, 2008 24 Linda A. Crockett, Notary Public 25

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